Saturday, April 15, 2006

To B2 OR NOT TO B2: musings on a blend specific RFS versus a volumetric RFS

Many of you have heard me express that I believe the biodiesel industry is supported by a two-legged stool of high petroleum prices and government support. You will also have likely heard me say that if one of those legs falls, the industry would likely contract, but would survive and that if both legs fell, the industry is dead.

There is not much one can do about the price of petroleum, so it is particularly important that biodiesel supporters get the government policy leg right. If the policies we advocate for end up too costly or onerous, we will risk losing these very policies. One of the key biodiesel policies being pursued is a patchwork of state biodiesel mandates or renewable fuel standards (RFS). Minnesota is the best-known example.

Minnesota’s legislature passed its B2 bill a few years ago, but the law only became effective last year when the trigger was satisfied. The bill requires that all diesel sold in Minnesota contain 2% biodiesel. I refer to this type of policy as a “blend specific RFS,” meaning that the blend itself is specified in the law, in Minnesota’s case 2% biodiesel or B2. Also worthy of note is the trigger Minnesota chose for when the requirement would take effect. Minnesota’s B2 bill was positioned primarily as an agricultural and rural economic development bill and accordingly the trigger that was chosen was that the state had enough biodiesel production capacity in state to satisfy the mandate. When two new 30 million gallon per year facilities came on line in Minnesota last year that threshold was crossed and the B2 requirement went into effect.

Contrary to the Minnesota blend specific model, the recently enacted (2005) Federal RFS, which includes both ethanol and biodiesel, is a volumetric requirement, meaning that no particular blend level is required, but rather, that the overall pool of fuel must contain at least a certain amount or volume of biofuel.

The second state to pass a biodiesel RFS was Washington State, which adopted a biodiesel and ethanol RFS earlier this year. Washington State’s biodiesel RFS was the result of a coalition of environmentalist and farmers. The bill began life as a Minnesota style B2 blend specific bill, but in the face of fierce opposition had to change to a Federal RFS style volumetric bill.

California now has a B2 biodiesel RFS winding its way through the legislative process. The bill is SB1675 (Kehoe) and is sponsored by Energy Independence Now. I have had the good fortune of working with the author, sponsor and other supports on the bill. Ever since I became aware of the bill, I have been trying to decide whether a blend specific or volumetric approach is preferable. I have consulted dozens of people in trying to answer this question and have come to the following conclusions.

Pros of B2 Mandate:
1) easy to monitor
2) gets renewable fuel into each gallon of diesel sold
3) provides a floor upon which to increase the percentage of renewable fuel in diesel
4) creates higher demand than an equivalent volumetric requirement (B20 and B100 market will continue to exist)
5) puts infrastructure in place for biodiesel blending at every terminal
6) no concern about increase in NOx
7) no engine warranty concerns

Cons of B2 Mandate:
1) difficult to implement - every terminal must be equipped to handle blending
2) will create lots of political opposition as all diesel users are hit (main concern is truckers and farmers)
3) higher implementation/transition costs as both low and high cost fuel providers and users are forced to make the switch
4) no significant air quality improvement

Pros of Volumetric:
1) harness power of market to maximize efficiencies and reduce cost of incorporating biodiesel into fuel mix
2) maximum flexibility for diesel users
3) encourages biodiesel to be used where it will have greatest environmental benefits (i.e. ports)
4) less political opposition from diesel users

Cons of Volumetric:
1) difficult to police
2) creates less demand for same % mandate (b/c existing and new B20 and B100 users likely included in mandate %)
3) potential for increased NOx emissions
4) potential for engine warranty issues

Depending on what hat I am wearing I come down on different sides of this debate.

When I am wearing my E2 hat, I lean toward the volumetric approach because of its flexibility and design to maximize the efficiencies of the marketplace. If a system to monitor and police the volumetric approach could be easily designed and implemented, I believe the volumetric approach would provide society with the greatest amount of renewable biodiesel at the least cost. A credit driven approach where excess credits can be freely traded, as with the Federal RFS, could be such a system. Layering a state-wide renewable fuel credit system on top of the Federal system would seem to create undue complication for fuel providers and as such I do not feel comfortable recommending such an option at this time.

When I am wearing my biodiesel industry hat, I lean towards the blend specific approach. It provides the greatest amount of certainty and would create the greatest amount of additional demand. It also creates an environment where all petroleum infrastructure is biodiesel ready and creates a low-blend baseline upon which to build.

Given the difficulty in designing a viable volumetric biodiesel RFS, I come down on the side of the B2 blend specific RFS. This provides the greatest increase in biodiesel use, vastly increasing the percentage of renewable fuel in the diesel fuel supply and reduces GHG emissions. The short-term transition costs to upgrade all petroleum facilities to handle biodiesel and blending of biodiesel is vastly outweighed by the benefits of biodiesel.

I encourage readers to come to their own conclusion and contribute to this discussion. Biodiesel and all of us who are believers in its potential will be better off as a result.

The other principal issue that comes up in designing a RFS is deciding on the trigger. As mentioned above, Minnesota chose in state production sufficient to met its mandate as its trigger. The Federal RFS chose time as its trigger, the volume of renewable fuel that must be in the total national fuel mix increase each year from 4 billion gallons in 2006 to 7.5 billion gallons in 2012.

What would be an appropriate trigger for California? Washington State chose a hybrid approach. The initial 2% volumetric requirement is timed based and becomes effective in 2008. The second phase trigger, where the volumetric requirement is increased from 2% to 5% is keyed to the production of in-state feedstocks equal to 3% of Washington State’s diesel consumption. This is rather different than Minnesota. Minnesota was already growing vast amounts of soybeans when it passed its RFS bill, but had very little biodiesel production. Accordingly, Minnesota in the name of rural economic development tied the implementation of its B2 mandate to in-state production.

Washington State on the other hand does not currently grow a significant amount of oil seed feedstocks. In order to gain the support of the farming community, the bill has to tie the second phase requirement to the growing of in-state feedstocks.

California is more like Washington State than Minnesota in that we do not currently grown a significant oil seed crop. I have proposed to the author and sponsor of SB 1675 that they consider both a Minnesota style in-state production trigger and a Washington State style in-sate feedstock growth trigger. I believe California industry and consumers can benefit from in-state production and that California agriculture can benefit from growing oil seed crops. Both of these should be explicitly encouraged in SB 1675.

Again, I encourage readers to come to their own conclusion and offer up their opinion on what triggers would be most appropriate for California. Feel free to offer any suggestion in the comment section of this blog or to email them to me directly at